Defendants.
)
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Without Presentation FIlED
MAR 15{ 2017
The undersigned complainant being duly sworn states: CU.:HK us DIS 1HIC1 COUf-lT .
SOUTHf:.HN DISTRICT OF CALIFORNIA
BY DEPUTY
On or about March 14, 2017, within the Southern District of California,
Defendant, Jose Emiliano AGUILAR, with the intent to violate the immigration laws
of the United States, knowing and in reckless disregard of the fact that aliens,
namely, Fenjiao FENG, Yuanzhang LIN, Lingling TANG and Yiming WANG had
not received prior official authorization to come to, enter and reside in the United
States, did bring to the ,United States said aliens, and upon arrival did not bring and
present said aliens immediately to an appropriate immigration officer at a designated
port of entry; in violation of Title 8, United States Code, Section 1324(a)(2)(B)(iii).

And the complainant states that this complaint is based on the attached
statement of facts, which is incorporated erein by refer nce.

The complainant states that Fenjiao FENG, Yuanzhang LIN, Lingling TANG, and
Yiming WANG are citizens of a country other than the United States; that said
aliens have admitted they are deportable; that their testimonies are material; that it
is impractical to secure their attendance at trial by subpoena; and that they are
material witnesses in relation to this criminal charge and should be held or
admitted to bail pursuant to Title 18, United States Code, Section 3144.

On March 14, 2017, at approximately 5:46 P.M., Jose Emiliano AGUILAR
(Defendant), a United States citizen, entered the United States from Mexico via the
San Ysidro, California Port of Entry. Defendant was the driver of a 2014 Chrysler
200 bearing California license plates with P.LC.J as a passenger. Upon inspection
before a United States Customs and Border Protection Officer, Defendant
identified himself with his United States Passport card while P.L.C.J. identified
herself with her Border Crossing Card (DSP-150). Defendant stated they were
going to San Diego, California and had nothing to declare from Mexico. During
primary inspection, a canine unit conducting pre-primary roving operations, alerted
to the vehicle's trunk. After Defendant unlocked the trunk the CBP canine officer
inspected it and saw several people hidden inside. Defendant and passenger were
secured and escorted to secondary inspection along with the vehicle.

In secondary, responding CBP Officers assisted and removed four people from the
trunk. The individuals, later identified as Fenjiao FENG (MWl), Yuanzhang LIN
(MW2), Lingling TANG (MW3) and Yiming WANG (MW4), were determined to
be Chinese citizens without lawful documents to enter or reside in the United
States and were held as Material Witnesses.

During a video recorded interview, the Material Witnesses admitted they are
citizens of China without lawful documents to enter the United States. Each
Material Witness said they made their own smuggling arrangements and agreed to
make a payment ranging from $3,000.00 to $60,000.00 if they successfully entered
the United States. Two Material Witnesses said they were going to Los Angeles,
California and two said they were going to New York, New York.